Award of third‑party visitation to maternal grandmother on alternating weekends, alternating holidays, and every Christmas Day was more than minimally intrusive of mother’s parental rights and thus impermissibly impinged on her fundamental constitutional right to make decisions concerning care, custody, and control of her child.

Parents had voluntarily placed their minor son in the guardianship of relatives. Some years later when the parents sought to terminate that legal guardianship and resume custody of their son, issues arose as to what, if any presumptions operated in favor of the parents’ and what burden of proof applied.